BIR Ruling No. 251-61

July 7, 1961 BIR RULING NO. 251-61 Messrs. Carlos J. Valdes & Co. Certified Public Accountants 6th Floor, San Luis Terraces 640 San Luis, Ermita Manila Gentlemen : Reference is made to your letter of the 26th ultimo, requesting information as follows: "This is in reference to the BIR Ruling Number 130 dated March 14, 1960 regarding the independence of a certified public accountant 'when he is retained as an external auditor and at the same time the stock and transfer agent of the same company'. Our question is as follows' is the independence of the CPA affected when he is merely appointed by the company to be their stock and transfer agent and will not be paid or retained for the work as transfer agent'?" In answer thereto, I have the honor to inform you that a certified public accountant cannot be retained by a company as its external auditor and at the same time appoint him as stock and transfer agent even if he will not be paid for the latter work. A contrary rule may open the door to fraud, for that would be permitting the certified public accountant to do indirectly what is prohibited to be done directly. cdpr Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue